Without an OSHA Ergonomics Standard, How Should You Address the Issue?

An employee of a California school district recently wrote to experts at Safety.BLR.com^®, asking how ergonomic issues in the workplace can be addressed when no ergonomics standard from OSHA exists. It’s a good question—and while there is no standard, there are resources available. See what the experts had to say on the matter.

Question: OSHA published a comprehensive ergonomics standard that was subsequently rescinded by Congress using the Congressional Review Act (CRA). Since that time, OSHA has been prohibited from passing another ergonomics standard. OSHA’s current approach is to publish ergonomic guidelines, which are not legally enforceable, for school districts with high incidence rates of MSDs and CTDs in the school district. What is your opinion of OSHA’s current approach to ergonomic issues in workplaces? And how do we as school districts address ergonomic issues in our workplace an approach would be better?

Answer: You are correct that there is currently no specific OSHA standard for ergonomics. However, under the General Duty Clause of the Occupational Safety and Health (OSH) Act, employers are required to ensure a workplace free from recognized hazards, including ergonomic hazards. While enforcement under The General Duty Clause does occur, OSHA will not focus its enforcement efforts on employers who are making good faith efforts to reduce ergonomic hazards.

To comply with the OSH Act General Duty Clause, you should implement an ergonomics program to address the hazards and minimize employees’ risk of injuries. The first step is to conduct a Job Hazard Analysis (JHA) to identity existing or possible hazards for jobs, especially those with a greater incidence of musculoskeletal disorders (MSDs).

OSHA has provided resources for industry or task-specific solutions to address MSD hazards. For teachers and administrators, resources related to computer workstation ergonomics could be applicable. For maintenance staff, resources for the construction industry may be applicable. For other types of employees in a school district (e.g., librarians, custodial staff, bus drivers, food service workers, security officers, and groundskeepers) there are no specific OSHA recommended practices. However, you should implement an ergonomics program to protect all workers.

OSHA recommends the following elements be integrated into an ergonomic process:

• A commitment by management (i.e. district administration).  Management should define clear goals and objectives, discuss them with their workers, assign responsibilities to selected staff members, and communicate with the workforce.
• Identify the ergonomic hazards in the workplace. Worker participation in worksite assessments, as well as the development and implementation of solutions can be useful.
• Provide training to workers—workers should understand the benefits of ergonomics and how it applies to the workplace and should know how to identify and report early symptoms of MSDs.
• Implement solutions to control hazards.
  • Engineering controls implement a physical change to the workplace, such as providing ergonomic computer station equipment and adjusting it to avoid awkward postures.
  • Administrative controls implement changes to processes or procedures, such as designing a job rotation system in which employees rotate between tasks that require different muscle groups.
  • Personal Protective Equipment (PPE) is an important control measure to reduce exposure to ergonomics-related risk factors.
  • Evaluate effectiveness of the ergonomic process and procedure to ensure continuous improvement and long-term success.

Additionally, California has an ergonomics regulation (8 CCR 5110) that is aimed at minimizing repetitive motion injuries (RMIs). The regulation is applicable to any employer where a repetitive job, process, or operation (e.g., word processing, assembly, or loading) has resulted in a physician-diagnosed RMI to more than one employee in the last 12 months. Every employer subject to the section must design a program to minimize RMIs, which shall include these three elements:

• A worksite evaluation of each job, process, or operation to determine exposures which have caused RMIs.
• The timely control of exposures which have caused RMIs.
• Employees shall be provided training that includes an explanation of:
  • The employer’s program;
  • The exposures which have been associated with RMIs;
  • The symptoms and consequences of injuries caused by repetitive motion;
  • The importance of reporting symptoms and injuries to the employer; and
  • Methods used by the employer to minimize RMIs.

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